Operational readiness resource

31-point AML Operating Load Checklist

For Australian conveyancing practices and independent property businesses assessing where recurring AML/CTF workload, ownership and evidence may sit.

AML support for conveyancers · View a fictional Health Check report

1. Real-estate service and property-rights scope

• We have identified whether we act as broker, principal seller, property developer, residential-site operator or another role for each relevant service.
• For leasehold interests, we record the base term separately from renewal, extension or further-term options.
• For licences and occupancy arrangements, we understand the actual rights, including exclusive possession, title registration and transfer or subletting rights.
• We check whether company shares or trust units confer a land-use entitlement or occupancy right.
• Uncertain property-right or designated-service classifications are referred for legal advice before the resulting AML/CTF implementation is set.

2. Ownership and governance

• We can identify our governing body and the senior manager responsible for approving the AML/CTF program.
• Our appointed AML/CTF Compliance Officer has documented authority, independence, resources and access to expertise.
• Responsibilities across offices, roles and central support teams are documented and understood.
• Material decisions and escalation points remain human-led and within documented authority.
• We have a calendar for AMLCO and governing-body reporting, including material risk-assessment updates.

3. Workflow and systems

• Our software configuration is mapped to our approved policies and actual operating process.
• Each onboarding, review, exception and remediation workflow has a named owner and due date.
• We know which work is performed locally, centrally, by vendors and by specialist advisers.
• We can see aged items, overdue actions, repeat exceptions and cross-office inconsistencies.
• System changes, workarounds and manual controls are documented and reviewed.

4. Evidence and exceptions

• We maintain an evidence register showing what exists, where it is securely stored and who can access it.
• CDD exceptions are triaged, assigned, escalated, decided and closed through a documented workflow.
• Our formal remediation register records the source of each finding, owners, due dates, dependencies, escalation and evidence required for closure.
• Training and personnel-due-diligence exceptions are visible and followed through.
• Customer identity data, transaction records and suspicious-matter details are kept out of public forms and ordinary email.

5. Monitoring and management visibility

• The AMLCO receives a concise recurring view of control health, actions, exceptions and next priorities.
• Management reporting distinguishes operational metrics from unresolved findings, control failures and matters requiring judgement or escalation.
• We periodically test whether key controls operate as intended and retain the scope, result, limitation and supporting evidence.
• External-audit, independent-evaluation and regulatory findings remain visible until evidenced closure.
• Our AUSTRAC enrolment status and any separate registration applicability are recorded distinctly, reconciled against AUSTRAC Online at least quarterly and when a change occurs, with changed enrolment details flagged for update within 14 days.
• Relevant regulatory changes, regulator correspondence and parent or group decisions affecting Australian controls are assessed and translated into operating actions.

6. Capacity and continuity

• Recurring AML tasks have realistic time allocations, backups and handover instructions.
• The AMLCO is not the sole person who understands the operating process or evidence structure.
• Vendor dependencies, access rights and service boundaries are documented.
• We can maintain essential controls during leave, staff turnover, system outages or high transaction periods.
• Open remediation work is prioritised against risk, operational capacity and governing-body expectations.

Reflection